Park Bank flood penalty
The FDIC issued a Notice of Civil Money Penalty, Findings of Fact and Conclusions of Law, Order to Pay, and Notice of Hearing to Park Bank, Holmen, WI, for engaging in a pattern or practice of committing violations of Part 339 of the FDIC's Rules and Regulations, 12 C.F.R. Part 339, which implements the requirements of the National Flood Insurance Act of 1968 ("NFIA") and the Flood Disaster Protection Act of 1973 ("FDPA"), as amended, 42 U.S.C. §§ 4001-4129. The bank had 20 days from service of the notice to request the hearing, or the penalty order would become effective.
The notice enumerated specific cases in which the bank force-placed flood coverage without the required 45-day borrower notice; failed to timely force-place coverage; failed to escrow flood coverage premiums when required; allowing inadequate coverage; failed to require adequate coverage at closing and failed to notify borrowers whether flood insurance was required.